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For the purposes of the credit (OETC) under s. 122.3(1), are the periods of stay abroad considered to be interrupted by the leave periods: where it is expected that: (1) they will return within a short period of time (usually two weeks) to work abroad on the same contract or on a new contract entered into by Canco; (2) where, upon the return to Canada, there is no planned foreign assignment (although the employee in fact will return abroad after that so that the cumulative length of the stays abroad, including holiday periods in Canada, will exceed 6 months); or with the variation on Situations 1 and 2 (so as to constitute Situations 3 and 4) that Canco issues a termination notice to the casual employee at the end of each stay abroad? ...

Comment in Summary: "The issue was considered by the Policy Review Committee and it was decided that it would not be appropriate to extend our long-standing favourable administrative position concerning dividend reinvestment plans of corporations to income distribution reinvestment plans of trusts. ...

Consequently, it seems to us that a payment made as “deferred salary” should not be considered a pension payment for the purposes of the Act and the Convention. ...

A be considered to be an excluded amount? CRA indicated that, as the Old Business had been wound up in a previous taxation year and ACo had no other related business, the dividends received were “excluded amounts” under (e)(i). ...

Accordingly, each of the three notional contribution components of the Supplemental Plan can be considered separately in determining whether the particular component is an SDA. ...

., from the time of the sale forward, the contribution is considered to have never occurred). ...

. … [F]or U.S. income tax purposes, the Canadian Branch profits of LLC3 are considered to be derived by the first entity in the corporate chain which is not treated as a fiscally transparent entity for U.S. income tax purposes. ...

XI(6)(b) of the US Treaty does not taint contemporaneous fixed interest 2016-0664041R3 dealt with a term loan which included both periodic non-participating interest payments, as well as future additional payments (the “Additional Amounts”) that were contingent on the index price of a particular commodity, and ruled that the former were not “participating debt interest” if, at or before the time of each payment thereof, no Additional Amount had been paid or become payable – but that all payments of periodic non-participating interest would be considered to be “participating debt interest” subject to withholding tax once an Additional Amount was paid or became payable. ...

14 May 2019 CLHIA Roundtable Q. 14, 2019-0799191C6- CLHIA Q. 14- IPPs and pension splitting-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(7)- Pension Income- Paragraph (a)- Subparagraph (a)(i) required top-up payments to satisfy the minimum-amount IPP rules do not qualify for income-splitting The definition of “permissible distributions” in Reg. 8502(d) seems to provide that the portion of the individual pension plan minimum amount that is not described as a “payment of benefits in accordance with the plan as registered” is considered to be a “permissible distribution”. ...

2018 Ruling 2018-0752531R3- Public corporation election 89(1)(c)(i)-- summary under Paragraph 4800(2)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 4800- Subsection 4800(2)- Paragraph 4800(2)(a) Reg. 4800(2)(a)(i) considered to be satisfied when, in fact, none of the shares held by the insiders had ever been listed since the Pubco’s formation by amalgamation Background Pubco was a corporation that was now closely held but was deemed to be a public corporation under s. 87(2)(ii) given that it resulted from the amalgamation of a public corporation and another predecessor. ...